Giuffre_Maxwell_Batch1_p00149.png

Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 16 of 28 4. Maria Alessi (3 % hours). Ms. Alessi’s deposition is scheduled for June 1, 2016, in Florida. She was, with her husband, household staff for Epstein in the Palm Beach home he shared with Defendant, and, it is anticipated, will corroborate many of the observations of her husband about minor girls and massages inside of Epstein’s Florida mansion. Mr. Alessi referenced during his prior deposition the things that Ms. Alessi observed with respect to the sexual massages and involvement of minor girls. Mrs. Alessi is also anticipated to testify regarding Ms. Maxwell's close association with Mr. Epstein and knowledge the visitors. 5. Dave Rodgers (3% hours). Mr. Rodgers's deposition is scheduled for June 3, 2016, in Florida. Rodgers was one of the pilots for Epstein’s private jets and will, it is anticipated, authenticate his flight logs showing Defendant and Ms. Giuffre together on the same flights. Defendant refused to admit that her name is reflected in the flight logs despite her initials “GM” appearing over 300 times. Therefore, such authentication is necessary because Defendant testified at her deposition she could not remember even the most basic things about flights in the flight logs. For example, when asked if “GM” represented her initials on the flight log, Defendant responded: “How do you know GM is me,” (See McCawley Decl. at Exhibit 5, Maxwell Depo. at 29 at. 122) and “GM can stand for any level, it could be Georgina, George.” (Cd. at 123). Ms. Giuffre is also seeking additional flight logs in Mr. Rodgers possession that will further corroborate Defendant’s involvement with Jeffrey Epstein. 6. Rinaldo Rizzo (3% hours). Mr. Rizzo is scheduled for June 10, 2016 and will be able to testify regarding his observations of Defendant and Epstein with underage girls (girls less than 18 years of age). Mr. Rizzo was originally set for deposition on May 13, 2016 which was noticed on April 11, 2016, and Defendant requested that Ms. Giuffre reschedule that deposition just days before the scheduled date. 12